Privacy Policy

Effective Date: October 26, 2026

Section 1. What This Privacy Policy Covers

This privacy policy (“Privacy Policy”) applies to personal information collected through the www.gilfoyle.org website and other products and services, including other websites, mobile apps, registration forms, and other digital properties (collectively, the “Site”), as expressly indicated by The Asuna P. Gilfoyle Foundation (the “Foundation,” “we,” “us,” or “our”), such as through a link or other display of this Privacy Policy (collectively, the “Services”). By visiting and/or using the Services, you have agreed to this Privacy Policy.

We are committed to protecting your personal information. This Privacy Policy describes what information we may collect about you; how we may use this information; what information of yours we might share with others; your choices in relation to your personal information; and how to contact us.

Section 2. What Personal Information We May Collect

We, or where relevant our designated service provider, collect personal information that you provide directly to us, such as through this Site, or that we receive from other sources. This includes personal information you provide when you fill out the “Contact Us” form, provide information for a grant application, complete a survey, or register for an event. We, or where relevant our designated service provider, may collect the following personal information about you:

  • Contact information and identifiers: name, email address, postal address, or other contact information, signature, online identifier, Internet Protocol address, or other similar identifiers;
  • Professional and educational history: professional, industry, employment-related, or educational information;
  • Survey data: certain information, including demographic information, when you respond to any surveys we may ask you to complete;
  • Site, device, and usage: your internet or other electronic network activity information, device information, language, operating system, the state or country from which you access the Services, browser type, browsing history, search history, the number of links you click within the Services, the functions you use, preferences, and information regarding your interaction with the Services or advertisements, which also includes your interactions through heatmaps and session replay;
  • Audio, electronic, visual, or similar information; and
  • Geolocation: data regarding your location collected via cookies or similar technologies placed on your device.

Personal information is obtained directly from you, from your activity when using the Services, and from other parties with whom we collaborate or work, such as service providers, business partners, advertising and data analytics providers, and social networks, as well as, where relevant, from law enforcement agencies. If you submit personal information about others, you represent and warrant that you are authorized to do so, that you have received authorization from the person about whom you are providing the information, and that such person has agreed to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

We require that users under 18 years of age or under the age of majority in their jurisdiction not submit personal information. In accordance with the U.S. federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we do not knowingly collect personal information from children under 13. We encourage parents to participate actively in their children’s Internet experience.

Section 3. What We May Use Personal Information For

We use personal information for carefully considered purposes which also benefit our users and which include some or all of the following:

  • to provide and facilitate our services and products;
  • to operate our services, products, and systems properly;
  • to communicate with you, including to provide you with newsletters and updates;
  • to help improve, upgrade, or enhance our services and products and develop new services and products;
  • to provide support for our Services;
  • to maintain the quality and safety of products and services, and for internal quality control purposes, including debugging to identify and repair errors that impair existing intended functionality;
  • to provide you with promotions and information regarding the Foundation or other parties that may be of interest to you, including through advertisements;
  • to enhance and personalize your experience with the Services, including to save your preferences;
  • to analyze Services usage, including to compile or use aggregate and anonymous information about usage of the Services;
  • to protect the interests, rights, safety, or property of the Foundation or others and to monitor compliance with and enforce the terms of any agreement with the Foundation;
  • to monitor and detect security incidents, to protect against malicious, deceptive, fraudulent, or illegal activity, and to hold those responsible for that activity accountable; and
  • to operate our organization and systems properly.

Some laws require us to describe the lawful basis for processing your personal information. Depending on the circumstances and the jurisdiction you are in, we process your personal information on one or more of the following lawful bases: (i) consent; (ii) processing is necessary for the performance of a contract; (iii) processing is necessary so that we can comply with our legal obligations and/or exercise legal rights; and (iv) processing is necessary for carefully considered purposes (“legitimate interest”). If we are processing your personal information on the basis of your consent, you have the right to withdraw that consent at any time.

Section 4. Use of Cookies and Other Electronic Technologies

Cookies are small pieces of data (alphanumeric files) that are placed on your device when you visit websites. They are commonly used to make websites work, or work more efficiently, as well as to provide information about your use of the website and to display content and advertising that is relevant to you. Other similar technologies can also be used to achieve these outcomes, including, for example, SDK tools (which are used on mobile apps), tracking pixels, advertising IDs, social media plug-ins, HTML local storage, and Local Shared Objects. We use the term “Cookies” to refer to both cookies and similar technologies.

We use Cookies for a variety of purposes, for example, to navigate between webpages efficiently, to allow our Services to remember your preferences, or to determine the popularity of our Services. Some of the Cookies that we use can track browsing behavior to help us understand how our Services are used so that we can improve them, or to compile aggregate and anonymous information about usage of the Services. Cookies can also help ensure that any advertisements that you see on our digital properties and other websites are more relevant to you and your interests.

You can change your Cookie preferences at any time by clicking on the Cookie Preferences icon at the bottom of the Site, and certain Cookies can also be disabled in your device settings if you are using a mobile app. Alternatively, most web browsers allow some control of most Cookies through the browser settings. Find out how to manage Cookies on popular browsers:

If you use a smartphone, you can usually prevent cross-site tracking and block Cookies in the settings section on your device. You need to set each browser on each device you use to access the Internet. Thus, if you use multiple browsers (e.g., Chrome, Safari, Edge, Firefox), you should repeat this procedure with each one. Similarly, if you connect to the Internet from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to use additional Cookie management tools.

To opt out of Google Analytics, you may install the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. We also use Microsoft Clarity to capture how you use and interact with our Services. Microsoft Clarity uses Cookies to capture this information. For more information on Microsoft Clarity, visit the Microsoft Privacy Statement at https://privacy.microsoft.com/privacystatement.

In addition, to learn more about behavioral advertising practices and how to opt out of Cookies placed for this purpose by member networks of the Network Advertising Initiative (“NAI”), you can visit www.networkadvertising.org. To opt out of advertising Cookies placed by participating companies in the Self-Regulatory Program for Online Behavioral Advertising, and thereby limit the tracking of your online activity and the targeted advertising you receive, please visit www.aboutads.info. Note that even if you exercise your choices for targeted advertising, you will still receive online advertising, but the advertisements will be more general in nature.

Section 5. How We May Use Your Personal Information for Marketing

Where you have chosen this, we may provide you with certain offers and promotions, including those of other parties, that may be of interest to you. We will provide an option to unsubscribe or opt out of further communication in any electronic marketing communication sent to you.

Please note that our marketing-related emails may contain a campaign-unique “web beacon pixel” to tell us how you interact with our communications. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should opt out of email marketing or read emails in plain text format.

You may instruct the Foundation at any time not to use your personal information collected in connection with your request to provide you with offers and promotions by following the unsubscribe mechanism in communications sent to you or by contacting us at [email protected]. Please note that these processes may take some time to complete, consistent with applicable law. Please also note that if you exercise choice in this manner, you will continue to receive communications concerning your account and the products and services you requested, and in response to any requests for information by you.

Where we may share your personal information with other parties, including our affiliates, interested in serving you or informing you about their organizations, you may instruct us at any time not to share your personal information with such third parties by contacting us at [email protected].

Section 6. How We May Share Your Personal Information

We may share your personal information with our affiliates, which may assist in providing the Services. We may also share your personal information with designated service providers, including for the purposes set out in this Privacy Policy. Service providers may include IT and marketing technology providers.

We may also share your personal information with unaffiliated third parties if we believe in good faith that such disclosure is necessary: (a) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) to protect the interests, rights, safety, or property of the Foundation or others; (d) to monitor compliance with and enforce any terms of use; (e) to provide our Services (including in connection with the transfer of any assets or allowing a purchaser or successor of the Foundation, any of our affiliates, or this Site to continue to serve you), and to perform other activities related to such services and products; (f) to provide you with information about our Services and those of third parties that may be of interest to you; or (g) to operate the systems that provide our Services properly.

We are not responsible for the collection, use, and/or disclosure of your information by affiliates and third parties, including, but not limited to, our partners. Such collection, use, and/or disclosure by partners, affiliates, or third parties is governed by their privacy policies.

We may use or disclose on this Site or elsewhere the information and contents of the material you submit, post, upload, or otherwise make available on this Site, such as in a grant application. You understand and agree that such information and contents of the material will not be treated as confidential by us. You further understand and agree that the outcome of any grant application that you submit will not be treated as confidential.

Section 7. Accuracy, Security, and Retention of Your Personal Information

We make commercially reasonable efforts to protect your personal information, and any personal information you provide to us is kept on secure servers. We use security measures appropriate to the provision of the relevant products or services, such as reasonable administrative, technical, personnel, and physical measures (a) designed to safeguard personal information on such servers against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of any username and password you set up in connection with your participation in the Services, if any.

Personal information is retained for as long as is necessary for the purpose(s) described in this Privacy Policy, including legitimate business reasons and/or legal and regulatory requirements. For example, personal information is retained if the information is reasonably necessary to manage your relationship with us or to provide our Services to you. To determine the appropriate retention period, we will generally consider the following criteria: the length of time needed to achieve the purpose for which your information was collected; whether you have ceased using our Services; the existence of any relevant legal proceedings; and applicable legal and regulatory requirements.

Section 8. Rights with Respect to Your Personal Information

Depending on the jurisdiction, you may have the following rights with respect to your personal information:

  • to confirm that we are processing your personal information;
  • to access and request certain information about the processing of personal information;
  • to obtain a portable copy of your personal information;
  • to obtain a list of the categories of third parties to which we have disclosed personal information;
  • to correct personal information;
  • to delete personal information;
  • to object to the processing of personal information;
  • to restrict processing of personal information;
  • to withdraw consent, where we have explicitly obtained it; and
  • to lodge a complaint with the relevant supervisory authority.

Please bear in mind that if you make such a request, this may affect our ability to provide our Services. To exercise a right related to your personal information, please contact us at [email protected]. Please include the following information in all requests: first name, last name, and email address, and “Privacy” in the subject line. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable law. Please note that it may take some time to process your request, consistent with applicable law. In the event that we cannot take action with respect to a request relating to your personal information, in certain jurisdictions you may have the right to appeal that decision by emailing us at [email protected].

We will comply with your request as soon as reasonably practicable, subject to legal requirements. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law.

If you choose to exercise these rights, we may ask that you provide sufficient information, including the Services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the type of request, we may ask for additional information.

Depending on the jurisdiction, you may have the right to use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.

U.S. residents may have specific rights in relation to opting out of the sale of personal information or its disclosure for targeted advertising. Please see Section 11 (Additional Information for U.S. State Residents) below for more information.

We will not discriminate against you for choosing to exercise any of your privacy rights.

Section 9. Transfer of Personal Information to Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our Services, you acknowledge and agree to the transfer of your information to the United States and other countries around the world that may not guarantee the same level of protection for such information as your country, and to the processing of your information in these countries. Where legally required, we implement appropriate safeguards to protect personal information that is transferred, which may include standard contractual clauses approved by the European Commission.

Section 10. Links to Third-Party Sites

This Site may contain links to third-party sites, including social networking sites. We are not responsible for any personal information you may provide while on such sites. Any information provided on such sites is governed by the privacy policies of those third-party sites. We encourage you to read the privacy policies on those sites before providing any of your information on such sites.

Section 11. Additional Information for U.S. State Residents

Certain information collected through the Site may constitute “sensitive personal information” as that term is defined by applicable U.S. state privacy laws. However, we only use such information to provide the Services or as otherwise permitted under applicable U.S. state privacy laws.

While we do not “sell” your personal information in exchange for money or “share” your personal information for cross-context behavioral advertising or targeted advertising outside of the use of electronic technologies to provide relevant advertisements, you may adjust your preferences by using the designated tool within the relevant digital property.

The Site is intended for a general audience and is not directed at children under the age of 16, nor do we have actual knowledge that we sell or disclose for targeted advertising the personal information of children under the age of 16. If you have knowledge that a child under the age of 16 has submitted personal information to us, we request that you contact us so that we may delete the information.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by the Foundation to its affiliates and/or third parties for their direct marketing purposes. To make such a request, please send an email with your first name, last name, mailing address, email address, and telephone number to [email protected]. Please include “California Privacy Rights” in the subject line of your email. You may also make such a request by writing to us at:

The Asuna P. Gilfoyle Foundation
Attn: Legal Department
113 Mill Plain Road, Suite 1014
Danbury, CT 06811

Section 12. Questions Regarding This Privacy Policy

If you have questions regarding this Privacy Policy, please contact us at [email protected].

Section 13. Modifications to This Privacy Policy

The Foundation reserves the right to change this Privacy Policy at any time by indicating revisions through the Effective Date at the top of this Privacy Policy. Such changes will be effective upon posting.